Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all users of the citi99 online betting and gaming platform accessible at https://citi99.cam (the "Website") and any associated mobile applications or services (collectively, the "Services"). By registering an account, accessing the Website, or using any of our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

citi99 operates under international gaming licenses and complies with applicable data protection laws and regulations in the jurisdictions where we are licensed. We are committed to maintaining the highest standards of data security and privacy protection for all our users, with particular attention to the needs and expectations of our Indonesian user base.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of the citi99 Services. If you do not agree with any aspect of this Privacy Policy, you must not use our Services.

2. Data Controller and Contact Information

citi99 acts as the data controller for all personal information collected through our Services. We are responsible for determining the purposes and means of processing your personal data in accordance with applicable data protection laws.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, you may contact our Data Protection Team:

• Email: [email protected]
• Live Chat: Available 24/7 through your account dashboard

We aim to respond to all privacy-related inquiries within 7 business days. For urgent matters related to data security or unauthorized account access, please contact us immediately via live chat for faster assistance.

3. Information We Collect

citi99 collects various types of personal information to provide, maintain, and improve our Services, ensure regulatory compliance, prevent fraud, and deliver a personalized user experience. The information we collect falls into the following categories:

3.1 Account Registration Information

When you create an account on citi99, we collect the following personal information:

• Personal Identification: Full legal name, date of birth, gender, nationality
• Contact Information: Email address, mobile phone number, residential address
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Communication Preferences: Marketing opt-in/opt-out status, preferred language, time zone

3.2 Verification and KYC Documents

To comply with international gaming regulations and anti-money laundering laws, we require all users to complete identity verification (Know Your Customer or KYC). This process involves collecting:

• Government-Issued Identification: Copies of your Indonesian National ID Card (KTP), passport, or driver's license
• Proof of Address: Recent utility bills, bank statements, or government correspondence showing your residential address
• Selfie Verification: Photographs of you holding your identification document for facial recognition verification
• Source of Funds Documentation: Bank statements, payslips, or other documents demonstrating the legitimate source of funds used for deposits (required for large transactions or suspicious activity)

3.3 Payment and Transaction Information

When you deposit funds into your citi99 account or request withdrawals, we collect and process:

• Banking Details: Bank name (such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), account number, account holder name
• Transaction History: Deposit amounts, withdrawal requests, timestamps, transaction status, payment method used
• Payment Verification: Copies of bank transfer receipts or screenshots (when required for verification purposes)

Please note that citi99 does not store your complete banking credentials or online banking passwords. We only store the information necessary to process your deposits and withdrawals through your chosen Indonesian bank.

3.4 Betting and Gaming Activity

To provide gaming services, detect fraud, ensure fair play, and comply with regulatory obligations, we collect detailed information about your betting and gaming activity:

• Bet History: Details of all bets placed including sport, event, market, odds, stake amount, potential winnings, and bet outcomes
• Game Play Records: Casino game sessions, slot spins, live dealer interactions, game outcomes, win/loss records
• Bonus Usage: Bonuses claimed, wagering progress, bonus terms acceptance, bonus expiration dates
• Account Balance: Current balance, historical balance changes, pending withdrawals, locked funds

3.5 Technical and Usage Data

When you access and use the citi99 Website or mobile applications, we automatically collect technical information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifier
• Connection Data: IP address, internet service provider, connection type, geographic location (country and city level)
• Usage Analytics: Pages visited, links clicked, time spent on pages, navigation paths, session duration
• Cookie Data: Information stored in cookies and similar tracking technologies (see Section 10 for details)

3.6 Communications and Customer Support

When you contact citi99 customer support or communicate with us through any channel, we collect:

• Support Inquiries: Content of your messages, support tickets, live chat transcripts, email correspondence
• Call Recordings: If applicable, recordings of phone conversations with customer support (where permitted by law and with your consent)
• Feedback and Surveys: Your responses to satisfaction surveys, product feedback, and promotional offers

4. How We Use Your Information

citi99 uses the personal information we collect for the following legitimate business purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your user account
• Processing your deposits and withdrawal requests
• Providing access to sports betting, casino games, and other gaming services
• Processing your bets and crediting winnings to your account
• Managing bonuses, promotions, and loyalty programs
• Communicating important account updates, security notices, and service announcements

4.2 Legal Compliance and Regulatory Obligations

• Verifying your identity and age to comply with gambling regulations (21+ requirement)
• Conducting KYC checks and ongoing due diligence to prevent identity fraud
• Monitoring transactions for suspicious activity and reporting to relevant authorities as required by anti-money laundering laws
• Maintaining records to comply with gaming license requirements and audits
• Responding to lawful requests from law enforcement, regulatory bodies, and courts

4.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent transactions, account takeovers, and unauthorized access
• Identifying and blocking duplicate accounts or accounts used for bonus abuse
• Monitoring betting patterns to detect match-fixing, collusion, or other forms of cheating
• Implementing security measures such as two-factor authentication and account verification
• Investigating suspected violations of our Terms & Conditions

4.4 Customer Support and Communication

• Responding to your inquiries, questions, and support requests
• Troubleshooting technical issues and resolving disputes
• Providing personalized assistance through live chat, email, and other channels
• Sending you important notifications about your account, transactions, and responsible gaming tools

4.5 Marketing and Promotional Communications (With Your Consent)

• Sending you information about new games, features, and platform updates
• Notifying you of special promotions, bonuses, and exclusive offers
• Inviting you to participate in tournaments, competitions, and loyalty programs
• Delivering personalized marketing content based on your gaming preferences and activity

You can opt out of marketing communications at any time through your account settings or by clicking the unsubscribe link in any promotional email. Please note that even if you opt out of marketing communications, we will still send you essential service-related messages such as transaction confirmations, security alerts, and policy updates.

4.6 Analytics and Service Improvement

• Analyzing user behavior and preferences to improve our Services
• Identifying popular games and betting markets to expand our offerings
• Testing new features and optimizing user experience
• Conducting research to develop better responsible gaming tools
• Generating statistical reports and business intelligence (using anonymized data)

5. Legal Basis for Processing

Under international data protection laws, citi99 must have a lawful basis for processing your personal information. We process your data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gambling services as outlined in our Terms & Conditions)
• Legal Obligation: Processing is required to comply with gambling regulations, anti-money laundering laws, and other legal requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, security, service improvement) provided these interests do not override your privacy rights
• Consent: You have given explicit consent for specific processing activities (such as marketing communications or optional features)

6. Data Sharing and Disclosure

citi99 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with carefully selected third parties in the following limited circumstances:

6.1 Payment Processors and Banking Partners

We share your payment information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and payment processing partners to facilitate deposits and withdrawals. These partners are contractually obligated to process your data securely and only for the purpose of completing your transactions.

6.2 Gaming Platform and Software Providers

We share limited user data with third-party gaming software providers who power our casino games, live dealer tables, and sports betting systems. This data is necessary to deliver game functionality and ensure fair play. These providers operate under strict confidentiality agreements and data protection requirements.

6.3 Identity Verification Services

We use specialized third-party services to conduct identity verification and KYC checks. These services may access your identification documents and personal details solely for the purpose of verifying your identity and age. All verification partners comply with international data protection standards.

6.4 Customer Support and Communications Tools

We use third-party customer support platforms to manage live chat, email ticketing, and customer inquiries. Your communications with our support team may be stored on these platforms, which are secured and compliant with data protection regulations.

6.5 Regulatory Authorities and Law Enforcement

We may disclose your personal information to regulatory bodies, law enforcement agencies, courts, or government authorities when required by law or when we believe in good faith that such disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Protect the rights, property, or safety of citi99, our users, or the public
• Prevent or investigate suspected fraud, money laundering, or other illegal activities
• Respond to claims that content violates the rights of third parties

6.6 Business Transfers

In the event that citi99 is involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity as part of the transaction. We will notify you of any such change and provide you with options regarding your data before the transfer takes place.

7. Data Security Measures

citi99 takes the security of your personal information extremely seriously. We implement industry-standard technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is protected by SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized personnel only on a need-to-know basis. All staff members undergo background checks and receive training on data protection and confidentiality.
• Secure Data Centers: Our servers are hosted in secure, professionally managed data centers with physical security controls including 24/7 surveillance, access logs, and environmental monitoring.
• Firewall Protection: Our systems are protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity.
• Regular Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential security risks.
• Account Security Features: We offer optional two-factor authentication (2FA) to add an extra layer of protection to your account.

Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

8. Data Retention

citi99 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

• Active Account Data: Retained for the duration of your account and for 7 years after account closure (as required by gaming regulations and financial record-keeping laws)
• KYC Documents: Retained for 7 years after account closure (regulatory requirement)
• Transaction Records: Retained for 7 years (financial record-keeping and anti-money laundering requirements)
• Marketing Communications: Retained until you opt out or withdraw consent, or for 3 years of inactivity
• Support Communications: Retained for 3 years from the date of the last communication

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with data protection laws.

9. Your Rights and Choices

Depending on your jurisdiction and applicable data protection laws, you may have the following rights regarding your personal information:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request that we delete your personal information, subject to legal retention requirements.
• Right to Restriction: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal information for marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Team at [email protected]. We will respond to your request within 30 days and may require verification of your identity before processing your request.

10. Cookies and Tracking Technologies

citi99 uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device when you visit our Website.

We use the following types of cookies:

• Essential Cookies: Required for the Website to function properly (login authentication, session management, security)
• Analytics Cookies: Help us understand how visitors use our Website (page views, navigation paths, time spent)
• Functionality Cookies: Remember your preferences and settings (language, time zone, display options)
• Marketing Cookies: Track your activity across websites to deliver targeted advertising (only with your consent)

You can control cookie settings through your browser preferences. However, disabling certain cookies may affect the functionality of the Website and your ability to use some features.

11. International Data Transfers

citi99 operates internationally and may transfer your personal information to servers located outside of Indonesia. When we transfer your data to other jurisdictions, we ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws.

By using our Services, you acknowledge and consent to the transfer of your personal information to countries that may have different data protection laws than Indonesia.

12. Children's Privacy

citi99 Services are strictly intended for individuals who are at least 21 years of age or the legal gambling age in their jurisdiction, whichever is higher. We do not knowingly collect personal information from individuals under the age of 21.

If we discover that we have inadvertently collected personal information from a minor, we will immediately delete that information and close the associated account. If you believe that we have collected information from a minor, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

citi99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, Services, legal requirements, or for other operational reasons. When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy.

If we make material changes that significantly affect your privacy rights, we will notify you by email (if you have provided an email address) or by posting a prominent notice on our Website at least 30 days before the changes take effect.

Your continued use of citi99 Services after any changes to this Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how citi99 handles your personal information, please contact our Data Protection Team:

• Email: [email protected]
• Live Chat: Available 24/7 through your account dashboard

Our customer support team operates 24 hours a day, 7 days a week, with native Indonesian-speaking agents available to assist you with any privacy-related inquiries.